In 2007, wild Puget Sound steelhead were listed as threatened under the Endangered Species Act (ESA). Seven years later, in 2014, the Wild Fish Conservancy (WFC) filed a lawsuit against the state of Washington claiming Puget Sound hatchery steelhead releases violated the act.

Washington Department of Fish & Wildlife (WDFW) settled out of court. The result was a suspension of hatchery plants on four of five targeted systems: the Snoqualmie, Stillaguamish, Nooksack, and Dungeness rivers. The Skykomish continues to receive a limited number of hatchery plants. The only marginally healthy system in Puget Sound—the Skagit/Sauk—will receive no hatchery plants for 12 years in conjunction with an extensive population study.

The news was met with cheers and jeers from the angling community. Wild fish advocates saw a potential win for steelhead recovery. Others saw a loss of angling opportunity.

A deeper read of the situation reveals that WDFW failed to provide proper hatchery genetic management plans (HGMPS) and obtain federal “take” permits required under the ESA. Instead, the agency was content with the illegal, status quo. No longer able to turn a blind eye, but forgoing any real leadership, NOAA decided to conduct an Environmental Assessment on the state of Puget Sound hatchery operations and impacts to wild steelhead populations. Essentially it was a cop out, a cursory study of the situation. WFC cried foul, again, claiming a far more thorough Environmental Impact Statement (EIS) was in order.

NOAA agreed, and released its draft EIS last month. The draft states that, “Hatchery production presents risks to natural-origin steelhead. These include genetic risks from hatchery-origin fish to natural-origin fish as a result of poor broodstock and rearing practices, risks of competition with and predation on naturally spawned populations, and incidental harvest of natural-origin fish in fisheries targeting hatchery-origin fish.”

Given the risks, the EIS recommended four options for the five Puget Sound watersheds concerned. One is no action, which ends hatchery operations in Puget Sound, giving wild fish a chance to recover without competition. The other three are continued hatchery plants, reduced hatchery plants, or a broodstock program, essentially a first generation hatchery program. WFC’s Nick Gayeski sees a problem with that, “By implication, any of the four alternatives should be capable of satisfying the ESA. But [NOAA] didn’t bother to figure that out before hand.” So, that begs the question: How can NOAA offer hatchery alternatives when it admits that hatchery fish threaten wild Puget Sound steelhead and has yet to determine if the alternatives violate the ESA?

Gayeski adds, “There’s nothing I’ve seen in the draft EIS that shows any additional substantive analysis to risks posed to wild steelhead in those rivers that’s any different than the faulty EA they issued in spring 2014.” In compliance with the ESA, NOAA is required to propose a comprehensive Puget Sound steelhead recovery plan, though no plan is forthcoming. That plan should identify what it would take to fully recover wild steelhead to satisfy ESA rules and what risks—e.g. hatcheries, harvest, hydro, habitat—are posed to the populations. Yet NOAA offers a draft EIS with hatchery alternatives, but without a plan on the table.

The question of hatcheries is contentious. Everyone agrees wild steelhead need to be saved, just not how to go about it. Plenty of anglers—both fly and gear—as well as treaty tribes, want hatchery steelhead to kill and eat or sell. And why not? It’s what we’ve known for generations and they taste great. Steelhead fishing is an economic generator, as well. The problem is no scientific or anecdotal evidence points to hatchery fish benefitting wild fish and plenty of evidence—including NOAA’s and WDFW’s own admissions—suggests hatchery fish adversely affect wild populations. At the very least, that suggests curtailing, if not ending, Chambers Creek hatchery releases in Puget Sound. Long time Washington steelhead guide Troy Dettman points to rivers without hatcheries that retain viable, wild populations, “It’s been shown on the John Day and the Wind that if we remove hatcheries, do in-stream habitat improvements, the wild steelhead increase in number. Hatchery costs are millions each year with no or little results, 1 to 3 percent returns. I feel strongly that given a chance the wild fish would repopulate the rivers in Puget Sound.”

The Toutle is a great illustration of this point. Mount St. Helens buried the river with mud and debris in the 1980 eruption. Yet, only half a decade later steelhead repopulated the river all on their own. The same thing is happening now on the Elwha, where two 100-year-old dams recently came down. ESA-listed salmon and steelhead were observed upstream of the old dam sites, very shortly after free flows were restored. A five-year angling moratorium was put in place to protect spawning salmon and steelhead. But rather than let the river heal itself, the Lower Elwha Klallam tribe, with the National Park Service’s blessing, spent $20 million in federal funds to build a shiny new hatchery. Though the subject is currently mired in litigation brought by WFC, Wild Steelhead Coalition, and other groups, the hatchery is currently releasing hatchery fish.

Dettman touches on another fractious issue, money. Hatcheries cost a lot to run. In 2012, each Puget Sound hatchery adult steelhead harvested cost an average of around $1,500 taxpayer dollars per fish. Can’t we put that money to better use? Think of the four Hs—the four broad categories used by biologists to define human impacts on wild salmon and their environment. (More specifically: Harvest, Habitat, Hydro, and Hatcheries.) They’re all human caused, negative impacts on wild steelhead. Large-scale habitat restoration projects are necessary for any recovery. If sport anglers can agree to just not kill wild steelhead and, dare I say, the state buy out some tribal netting rights with that money, maybe, just possibly we can take care of all four H’s. Dettman points to harvest as well, “We need to address sport harvest and the tribal netting around Puget Sound and elsewhere [the Olympic Peninsula] if we are going to save any wild steelhead. We need to work with the tribes if we are all going to have anything to fish for.”

Another solution: Washington State began a steelhead gene bank program in 2012, creating a wild steelhead management zone on the Sol Duc River, harboring one of the few relatively healthy runs left in the state. Three more rivers were added since and the Skagit/Sauk—which contains the biggest viable run and best habitat in Puget Sound—is currently under consideration for the designation. This program brings up an important question. Why can’t we have both selective hatchery and wild runs on separate rivers? And why can’t the state identify rivers with runs worth saving and do just that? The gene-banking program is already a step in that direction. Isn’t it worth exploring more in-depth?

John McMillan, science director for Trout Unlimited’s Wild Steelhead Initiative, says this is the right time for change. “Anglers are looking for new solutions because what we’re doing isn’t working. We don’t want to just see management from the hip, every couple of years. That’s why we’re proposing a large scale research program.” McMillan notes that steelhead management is not a one-size-fits-all solution, and a research program will study the differences in steelhead life histories in different watersheds—what he calls the Portfolio Effect—and apply that research to adaptive management. The Chambers Creek hatchery program is the prime example of failed, cluster-bomb management rather than adaptive strategies. “The hatchery fish we do or don’t put in [rivers] should depend on the rivers’ inherent ability to produce and recover fishable populations of steelhead,” says McMillan.

If NOAA and WDFW put that advice into play, angler wishes for protected wild populations separated from harvest opportunity may harmonize.

So what does wild steelhead recovery actually look like for these five watersheds, Puget Sound, and the whole state? If hatcheries have a role, it’s a carefully targeted and managed one. Given the options laid out in the recent draft EIS, NOAA may opt for hatchery status quo, but officially doesn’t have an opinion, yet... Kurt Beardslee of WFC makes an important point, “It’s often framed as either hatchery fish or no fishing, and it doesn’t have to be that way.” Given strict C&R guidelines and angler education, recreational fisheries should have little harm on wild steelhead populations. McMillan adds, “We want meaningful change but continued divisiveness will not get us anywhere.”

[Public comment on NOAA’s draft EIS is open through Dec. 28. Make your voice heard. Email: This email address is being protected from spambots. You need JavaScript enabled to view it.]